DISSENTING OPINION BY
Judge COHN.Respectfully, I dissent. My interpretation of what constitutes the factual findings in this case leads me to a different conclusion than that of the majority. Accordingly, I reiterate the critical facts as I perceive them to be and then apply them to the law, noting at the outset that for the *1043past twenty years, Price has paid the real estate taxes on both properties every other year; that is, she allows them to accumulate for two years before paying them.
Notice Regarding the Commercial Propertg
On April 17, 1998, the Montgomery County Tax Claim Bureau (Bureau) sent a “Notice of Return and Claim” to JUL Realty by certified mail, return receipt requested, showing delinquent real estate taxes for the tax year 1997 in the amount of $8455.81. On April 1, 1999, the Bureau sent a “Notice of Return and Claim” to JUL Realty by certified mail, return receipt requested, showing delinquent real estate taxes for the tax year 1998 in the amount of $7411.60. On May 28, 1999, the Bureau sent notice to JUL Realty by certified mail of the tax sale. The notice indicated that the Commercial Property would be sold at a tax sale on September 13, 1999. Price admits that she received the above notices. However, when she read the date of the tax sale on the certified mail notice, she thought it was September 15, 1999, instead of September 13, 1999. Price pointed out that she is 73 years old and wears reading glasses. She did not recall ever reviewing the notices while wearing her glasses. The trial court found, as a matter of fact, that, although the print on the notices was somewhat fight, the date of the tax sale on the notice by certified mail was legible to a person with normal or normally-corrected vision.
Notice by first class mail was sent to JUL Realty on August 27, 1999.1 Price acknowledged that she received this notice as well. Price produced the original notice by first class mail at the hearing. She did not testify that she had misread the date. The trial court found, as a matter of fact, that, although the print was somewhat light, the date of the tax sale on the notice by regular mail was legible to a person with normal or normally-corrected vision.
Notice of the tax sale of the Commercial Property was published once on August 5, 1999, in The Norristown Times Herald, The Pottstown Mercury, and The Montgomery County Law Reporter.
The Sheriffs Department in Montgomery County is responsible for serving personal notice and posted notice. Deputy James Conway handled the posting and personal service notices. After posting a property or personally serving a property owner with a tax sale notice, Deputy Conway immediately fills out an affidavit re-fleeting the circumstances of the posting or personal service. With regard to the Commercial Property, Deputy Conway’s affidavit stated that on July 27, 1999, at approximately 8:30 a.m., he visited the Commercial Property and posted the property and personally served Price with notice of the tax sale.
Notice Regarding the Residential Property
On May 28,1999, the Bureau sent notice of the tax sale of the Residential Property to Price by certified mail. The notice indicated that the Residential Property would be sold on September 13, 1999. Price admits that she received the notice by certified mail. However, again, Price did not have on her reading glasses and she thought that the date of the tax sale was September 15, 1999, instead of September 13, 1999. The trial court found, as a mat*1044ter of fact, that the notice, although in somewhat light print, was legible to a person with normal or normally-corrected vision.
Although notice by regular mail is not required by the statute, the Bureau sent such notice on August 27, 1999. This notice also indicated that the Residential Property would be sold at a tax upset sale on September 13, 1999. Price admits that she received notice by regular mail. Again, she did not testify that she misread the tax sale date on this notice. The trial court, again, found as a matter of fact that the date of the tax sale on the regular mail notice was legible to a person with normal or normally-corrected vision.
Notice of the tax sale of the Residential Property was published once on August 5, 1999, in the identical publications in which publication notice of the Commercial Property was achieved.
Deputy Conway also handled the posting and personal service of the tax sale of the Residential Property. According to his affidavit, Deputy Conway posted a notice of tax sale on the main front door of the Residential Property at 7:45 a.m. on July 27, 1999. Deputy Conway also knocked on the main front door so that he could personally serve Price -with notice of the tax sale, but received no response. Deputy Conway then went to the kitchen door and knocked there. He saw Price through the door when he knocked, but she did not respond. Deputy Conway then posted the personal service copy of the tax sale notice on the main front door and returned an Affidavit of Service that stated Price “would not come to the door, left as a refusal.”
Both properties were sold at a tax sale on September 13, 1999. Price attempted to pay the delinquent taxes on September 15, 1999. Both properties were purchased by Michael Candidio, Irvin E. Povlow, Michael Singer and Homeowners Concepts, Inc. (Purchasers). Price filed exceptions to the tax sale, which the trial court denied following hearing. This appeal followed.2
A. Commercial Property
Price argues and the majority agrees that the tax sale should be set aside because posted notice of the tax sale of the Commercial Property was improper.
Purchasers contend that the trial court was correct in determining that posted notice was proper and cannot be challenged because the Bureau submitted the sheriffs affidavit. They assert that the sheriffs affidavit is conclusive proof of posting and cannot be collaterally attacked. The sheriffs affidavit stated that the Commercial Property was posted on July 27,1999, at 8:30 a.m., and is signed by Deputy Conway.
In reaching its decision, the trial court relied on Hollinger v. Hollinger, 416 Pa. 473, 206 A.2d 1 (1965), for the proposition that the information contained in the sheriffs affidavit is conclusive and cannot be collaterally attacked. The trial court, thus, did not permit Price to challenge the affidavit. The majority correctly states the legal principles in Hollinger as to the conclusive nature of the sheriffs affidavit and the manner in which that conclusiveness can be rebutted. But, it then goes on to state, “Deputy Conway’s .testimony constitutes evidence that contradicts the affidavits.” Slip op. p. 6. It is here that I part *1045company with the majority. First, in deciding that Sheriff Conway’s testimony constituted such evidence, the majority has made a crucial credibility decision, which we are not permitted to do. Second, Hol-linger must be read in context. Although the case is instructive, generally, in explaining the conclusiveness of documents executed by public officers in the course of their duties, there is a fine of cases that addresses, more specifically, the conclusiveness of a sheriffs affidavit in the context of tax sales. In such cases, there exists a prima facie presumption of the regularity of the acts of public officers, until the contrary appears. Thomas v. Montgomery County Tax Claim Bureau, 123 Pa.Cmwlth. 371, 553 A.2d 1044 (1989), petition for allowance of appeal denied, 523 Pa. 652, 567 A.2d 655 (1989). A property owner can overcome the presumption “[b]y filing exceptions to a tax sale, averring that the statutory notice provisions were not complied with, [and thus creating] a contrary appearance.” Ali v. Montgomery County Tax Claim Bureau, 124 Pa.Cmwlth. 557, 557 A.2d 35, 37 (1989). Then the tax claim bureau, or a purchaser arguing that the tax sale was proper, has the burden of proving that the tax claim bureau complied with the notice provisions. Upset Price Tax Sale of September 10, 1990 (Sortino) v. Delaware County Tax Claim Bureau, 147 Pa.Cmwlth.52, 606 A.2d 1255 (1992). I believe these cases are more applicable to the current matter and provide the legal framework that should be used here.
Applying this law to the case sub judice, I note that Price filed exceptions to the tax sale of the Commercial Property and averred that posted notice was not achieved in compliance with the statutory provisions as set forth in the Law. By doing so, Price raised a contrary appearance as to the information stated in the sheriffs affidavit. Consequently, the Bureau and Purchasers then had the burden of showing compliance. They submitted the affidavit and called Deputy Conway to testify on this issue. However, because the trial court determined that the affidavit was conclusive, it made no findings of fact or credibility determinations as to Deputy Conway’s testimony.
At the hearing on January 23, 2001, almost eighteen months after the events, Deputy Conway testified, on direct examination, that he posted the notice of the tax sale on the front door of the building at the Commercial Property. (N.T., January 23, 2001 Hearing, p. 105 .) He next stated that, upon seeing Price drive up in her car, he had a brief conversation with her and then handed her the personal service notice.3 (N.T., January 23, 2001 Hearing, p. 107.) On cross-examination, Deputy Conway stated that he taped the notice on the front door. (N.T., January 23, 2001 Hearing, p. 113.) Upon further questioning, he said that when he saw Price drive up in her car to the Commercial Property, he might have taken the posted notice off the door and handed both the posted and personal service notices of the impending tax sale of the Commercial Property to her, or she might have taken the notice off. (N.T., January 23, 2001 Hearing, p. 119-120.) Specifically, he states: “In this case, I went up there, I posted the property, turned around and I saw Mary [Price]. *1046Whether I gave her the posted copy, took it off the door, I’m not one hundred percent. She did get both copies.” (N.T., January 28, 2001 Hearing, p. 110.) And later, “I went up and I posted it, turned and saw her, so I took it off and gave her both copies. She was served with both of them.” (N.T., January 28, 2001 Hearing, p. 113.) He testified that he knows Mary Price because he has served her numerous times in the past. (Deposition of Deputy Conway, p. 8).
Given the fact that Deputy Conway’s testimony is not conclusive, I believe that it is solely within the trial court’s role as a fact finder to determine exactly what occurred. Over time memories fade, and extensive cross examination about events that occurred many months before can create confusion. Particularly, in this type of situation, where Deputy Conway testified that he can serve four hundred tax sale notices during a tax sale season, it can be difficult for a sheriffs deputy to remember every detail of a particular service. This was one of the concerns underlying the Hollinger rule because it is unrealistic to demand perfect recall of one particular occurrence of an activity that is routinely, and repetitively, performed by a public officer in the course of his official duties.
It is, therefore, the responsibility of the trial court, as fact finder, to determine whether Deputy Conway’s affidavit, which was executed contemporaneously with the events, is accurate, or which version of his subsequent testimony most credibly sets out what occurred and, therefore, whether notice was properly given.
B. Residential Property
Price also argues that the tax sale of the Residential Property should be set aside because personal service notice was improper. Purchasers again contend that the sheriffs affidavit, executed by Deputy Conway as to personal service notice, is conclusive evidence that personal service was made. However, based on the above discussion, the sheriffs affidavit is not, in my view, conclusive because Price raised a contrary appearance when she filed her exceptions to the tax sale. Ali. Consequently, Purchasers were required to show that the Bureau complied with the statutory requirements, and attempted to do so with the affidavit and testimony of Deputy Conway. The trial court, again, determined that the sheriffs affidavit was conclusive as to whether personal service notice was made pursuant to Hollinger. However, based on the above discussion of the law pertáining to sheriffs affidavits in the context of a tax sale case, it is, in my view, necessary for the trial court to evaluate the testimony of Deputy Conway and Price, and make credibility determinations in reaching its decision.
On the affidavit, Deputy Conway had written “would not come to the door, left as a refusal.” (Affidavit of Upset Sale Personal Service, Trial Exhibit R6.) During his deposition on June 8, 2000, nearly 11 months after the date of posting, Deputy Conway stated that he saw Mrs. Price in her kitchen, that he knew who she was because he had served her numerous times in the past, that her car was in the driveway, that he knocked three times and, that when she did not come to the door, he posted the notice and made the notations on the affidavit. (Deposition of Deputy Conway, pp. 8-9.) He also stated that he physically saw her turn around when he knocked, but did not remember whether she made eye contact with him. (Deposition of Deputy Conway, p. 10.) During the hearing on January 23, 2001, nearly 18 months after the date of posting, Deputy Conway testified that he remembered the property very well because he had been there numerous times in the past to serve *1047tax notices, as well as other civil actions. In the case sub judice, he attached the notice to the front door with tape, and was certain it was Mary Price he saw that day. (N.T., January 23, 2001 Hearing, pp. 76, 81-82.) During cross examination, he stated that he knocked on the door of the Residential Property and saw Price through the door. (N.T., January 23, 2001 Hearing, p. 92.) He did not recall whether Price made eye contact with him or not when he knocked on the door. (N.T., January 23, 2001 Hearing, p. 92.) Ultimately, Price never responded to his knock on the door. After considerable cross examination, Deputy Conway finally stated that “I don’t believe she saw me or heard me either way. Because, if she did, she would have came [sic] and answered the door.” (N.T., January 23, 2001 Hearing, p. 93.) Because he received no response, Deputy Conway placed the personal service notice on the door next to the posted notice and indicated on the affidavit that Price “would not come to the door, left as a refusal.” (Affidavit of Upset Sale Personal Service, Trial Exhibit R6.) He also indicated that service was made at 7:45 a.m. on July 27, 1999. Id. Price, on the other hand, testified that she was out of her home at the time, and that he, therefore, could not have seen her.
I believe that it is within the trial court’s role as a fact finder to determine exactly what occurred when Deputy Conway attempted to serve personal service notice on Price. It is possible that the trial court will believe Deputy Conway’s affidavit, which was contemporaneous with the events, or his testimony which evidences a refusal; it is also possible that the trial court will believe that the Deputy did not effectuate personal service. Absent these findings, I believe the Court is unable to complete meaningful appellate review. Consequently, I would vacate the order and remand to the trial court to consider the testimony of Deputy Conway and make credibility determinations in reaching a decision on whether the notices at issue here were properly effected.
Accordingly, I dissent.
Judge PELLEGRINI and Judge LEADBETTER join in this dissenting opinion.
. Purchasers point out that first class mail notice is only required if the Bureau does not receive the certified mail “return receipt" bearing the owner’s signature. See Section 602(e)(2) of the Real Estate Tax Sale Law, Act of July 7, 1947, P.L. 1368, as amended, 72 P.S. 5860.602(e)(2). Here, there is no dispute that certified mail was accomplished. The Bureau, nevertheless, sent the first class mail notice also.
. The standard of review in tax sale cases is limited to whether the trial court abused its discretion, rendered a decision with a lack of supporting evidence, or clearly erred as a matter of law. Matter of the Tax Sales by the Tax Claim Bureau of Dauphin County, 651 A.2d 1157 (Pa.Cmwlth.1994), petition for allowance of appeal denied, 544 Pa. 650, 664 A.2d 978 (1995).
. Personal service notice is required to be served on a owner-occupant of a property pursuant to Section 601 of the Law, 72 P.S. § 5860.601; that is, personal service notice must be served on the owner residing at the property. The Commercial Property, not being a residence, does not require that personal service notice be served on Price. Rather, the Bureau is only required to show that certified mail notice, published notice, and posted notice were accomplished pursuant to Section 602 of Law.